20171122Sierra Club 1-16 to IPC.pdf

Kelsey Jae Nunez, ISB No. 7899
KELSEY JAE NUNEZLLC
920 N. Clover Dr.
Boise,ID 83703
Telephone: [phone]
kelsey@kel seyj aenunez. com
Attorney for Sierra Club
RECE IVED
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Zack Waterman
IDAHO SIERRA CLUB
503 W Franklin St
Boise, lD 83702
Telephone: [phone]
zack. waterman@si erraclub. org
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR AUTHORITY
TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL
AND SMALL GENERAL SERVICE CUSTOMERS WITH
ON-SITE GENERATION
IPC-E-17-13
IDAHO SIERRA CLUB'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY
COMES NOW Idaho Sierra Club, by and through its attomey of record, Kelsey Jae
Nunez of the firm Kelsey Jae Nunez LLC, request that Idaho Power Company ("Idaho Power" or
"the Company") provide the following documents and information as soon as possible, and no
later than 2l days from November 22,2017.
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced. Please provide answers to each question
and supporting workpapers that provide detail or are the source of information used in
calculations, and in addition to written copies, please provide any Excel and electronic files on
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-17-13 - I
CD with formulas active. Additionally, please include the name and phone number of the person
preparing the document, and the name, location, and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. As allowed by IDAPA
31.01.01 .228.01, if any response is voluminous Sierra Club agrees to Idaho Power depositing the
response in an electronic depository.
PLEASE SERVE ANY HARD COPIES OR CDS TO KELSEY NUNEZ AT THE
ADDRESS ABOVE AND TOM BEACH AT:
Crossborder Energy
2560 gth Street, Suite 2l34.
Berkeley CA94710
REOUEST NO 1. Please provide the most recently used alternate, marginal, or avoided
costs for analyzing demand side resources, including Idaho Power's energy efficiency and
demand response resources. Please provide these costs for each hour of the year and for the
future 20 years. Please provide these costs in Excel spreadsheet format.
REOUEST NO 2. For the alternate, marginal, or avoided cost data requested above,
please identify and quantiff the following components. If Idaho Power has not identified or
quantified any of the following, please explain why not.
a. Energy
b. Generation Capacity
c. Transmission
d. Distribution
e. Operations and maintenance
f. Avoided line losses identified and quantified separately for the transmission and
distribution systems.
g. Any other components Idaho Power includes in alternate costs not specifically
referred to in a-f.
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-I7-13 - 2
Please provide the workpapers and calculations used to develop each of the above components
that Idaho Power has calculated. Please provide these workpapers and calculations in Excel
spreadsheet format.
REOUEST NO 3. Please provide Idaho Power's most recent marginal cost study,
including marginal costs for transmission and distribution capacity, comparable to the marginal
costs that Idaho Power included in its 2011 general rate case showing. See 201I Marginal Cost
Analysis, Larkin Workpapers at 59-66, IPC-E-I l-08, (April28,20ll memo from Scott Wright to
Matt Larkin). Please provide the workpapers for this study in Excel spreadsheet format.
REOUEST NO 4. Please provide the following information concerning the
implementation of time-differentiated rates on the ldaho Power systern:
a. Please describe the time-of-use (TOU) or time-differentiated rates that the
Company offers to its residential and small commercial customers. Please provide the number of
residential and small commercial customers on TOU rates today, in absolute numbers and as a
percentage of the total number of customers in these classes.
b. Does Idaho Power have a customer information and billing system capable of
implementing time-differentiated rates for all of its customers? If it does not, please describe the
billing and customer service constraints Idaho Power faces in moving to time-differentiated rates
for all of its customers.
c. Does Idaho Power have an advanced metering infrastructure (AMD capable of
implementing time-differentiated rates for all of its customers? If it does not, please describe the
metering constraints Idaho Power faces in moving to time-differentiated rates for all of its
customers.
Idaho Sierra CIub - First Production Request to Idaho Power Company - IPC-E-I7-13 - 3
d. Does Idaho Power have a customer information and billing system capable of
applying time-differentiated rates for net metering service? Please describe in further detail the
complexity of the calculations to implernent time differentiated rates for net metering customers.
e. Does Idaho Power have 2-channel meters capable of recording separately (l) the
power that Idaho Power supplies to a customer with on-site generation and (2) the power that
such a customer exports to Idaho Power? If not, why not?
f. Does Idaho Power plan in the future to move to the use of 2-channel meters for
customers with on-site generation? If not, why not?
REOUEST NO 5. Does Idaho Power's Fixed Cost Adjustment mechanism address the
recovery of fixed costs that are affected by any change in customer energy consumption,
including from the installation of customer-sited generation, such that Idaho Power shareholders
are not impacted? If not, why not?
REOUEST NO 6. Please provide the Company's most recent cost-effectiveness analyses
of its demand-side resources, including EE and DR programs, that it has submitted to the
Commission. Please include all workpapers for these cost-effectiveness analyses, including the
alternate or avoided costs that the Company used, in Excel spreadsheet format.
REOUEST NO 7. Please provide in Excel spreadsheet format the hourly load curves and
data for the most recent calendar year period for the Idaho jurisdiction of Idaho Power's system
for the following customer classes:
Residential
Small General Service
REOUEST NO 8. Please provide in Excel spreadsheet format the monthly Idaho
jurisdiction retail peak demands and consumption for the most recent calendar year for the entire
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-I7-13 - 4
a.
b.
system and by customer class, as well as the date and time on which each of those peaks
occurred.
REOUEST NO 9. Please provide the average monthly consumption per customer for the
residential and small general service classes for calendar years 2007 through 2016.
REOUEST NO 10. Please provide any study that ldaho Power has performed that
specifically and separately identifies and quantifies the long-term benefits provided to Idaho
Power by the installation of customer-sited distributed generation, including solar, wind, and
small hydro technologies.
REOUEST NO 11. Please provide all studies, reports, testimony, analyses, and state
commission decisions that Idaho Power, including its executives and witnesses in this case, have
reviewed concerning the following:
a. the benefits and/or costs of distributed generation or net-metered renewable
generation in states other than Idaho
b. cost-of-service analyses for customers who install on-site distributed generation
c. alternatives to net metering that have been developed in other states.
REOUEST NO 12. Does Idaho Power agree that net-metered systems are qualifoing
facilities under PURPA? [f not, why not?
REOUEST NQ 13. Net metered solar photovoltaic generation is not the only type of
distributed energy resource (DER) that can significantly impact a customer's load profile or
result in exports of power to the Idaho Power distribution system. Other DERs include
programmable thermostats, various types of on-site energy storage including batteries and
thermal storage, electric vehicles, and demand response programs.
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-I7-13 - 5
a. Please explain whether the Company intends to create a distinct customer class
for each type of DER that might be added to its system. If the Company does not, please justify
which tlpes of DER will merit a separate customer class and which will not.
b. Please explain whether the Company intends to create a distinct customer class
for each combination of DERs that might be added to its system, for example, solar plus on-site
storage, or solar plus EVs with time-differentiated rates for charging. If not, please justifu which
combinations of DERs will merit a separate customer class and which will not.
REOUEST NO 14. This request builds upon Vote Solar's Request for Production No
40.
a. Please provide Idaho Power's definition of "DER" used in that response.
b. Please provide the number & technology of DER units and the total capacity of
such units by technology, on each of the circuits for which 66DER" penetration exceeds 150lo.
c. Please specify the peak load and maximum capacity of each circuit identified in
the response to Vote Solar's Request No. 40.
d. Please provide a recent calendar year (2016) ofhourly load data in Excel
spreadsheet format on each of the circuits for which "DER" penetration exceeds l5olo.
REQUEST NO 15. Please provide Idaho Power's most recent plan for future upgrades to
its distribution system that are intended to serve load growth. This should include:
a. A list of distribution circuits and substations planned to be upgraded.
b. The current peak capacity of each of these distribution circuits and substations.
c. The recent peak loads, and the forecasted load growth (i.e. the o/o increase in peak
demand each year) on each of these distribution circuits and substations.
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-I7-13 - 6
d. The expected cost and in-service date ofeach planned upgrade, and the kW of
capacity added with each upgrade.
e.For each distribution substation (not circuit) planned to be upgraded, please
provide a recent calendar year (2016) of hourly load data in Excel spreadsheet format for each of
these substations, and indicate the maximum capacity of each such substation.
REOUEST NO 16. Please provide Idaho Power's most recent plan for future upgrades
or additions to its transmission syston, including high-voltage bulk transmission. This should
include:
a. A list of transmission lines and substations planned to be added or upgraded, their
voltage level, and the principal reason for each addition or upgrade.
b. The expected capital cost and in-service date of each planned transmission
addition or upgrade.
Dated this 22nd day of November, 2017.
Respectfully submitted,
t$\e N'ut"td
Kelsey Jae Nunez, Attorney for Sierra Club
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-17-13 - 7
CERTIFICATE OF SERVICE
I certify that on this 22nd day of Novernber, 2017, true and correct copies of the above FIRST
PRODUCTION REQUEST TO IDAHO POWER COMPANY were sent to the following
persons via the methods noted:
Emailed:
Idaho Power Company
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
l22l W.Idaho St.
PO Box 70
Boise,Idaho 83707
lnordstrom@idahopower. com
dockets@idahopower. com
ttatum@idahopower. com
cashenbrenner@ i dahopo wer. com
Commission Staff
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise,Idaho 83702
sean. costel lo (@puo. i daho. gov
Idahydro
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise,ID 83701
tom. arkoo sh (@ arkoo sh. com
erin. [e-mail]
Idaho lrrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
PO Box 6l 19
Pocatello, Idaho 83205
elo(rD,echohawk.com
12700 Lake Ave. Unit 2505
Lakewood, OH44107
Email : tony(rDyankel.net
Idaho Conservation League
Matthew A. Nykiel
PO Box 2309
102 S. Euclid#207
Sandpoint,ID 83864
mnvki el @,idahoconservation. ore
Ben Otto
Tl0N6thStreet
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
botto (gi dahocon servati on. ors
Auric Solar, LLC
Elias Bishop
2310 s. 1300 w.
West Valley City, UT 84119
Telephone: (801 ) 878-3363
elias.bishop@auricsolar. com
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLP
601 W. Bannock St. Boise, lD 83702
prestoncarter@ givenspursley. com
den@ givenspursley.com
City of Boise
Abigail R. GermaineAnthony Yankel
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-17-13 - 8
Deputy City Attorney
Boise City Attorney's Office
105 N. Capitol Blvd.
P0 Box 500
Boise,ID 83701-0500
agermaine@cityofboi se. ors
Idaho Clean Energy Association
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise, ID 83701
tom. arkoo sh(g2arkoo sh. co m
enn. ce cil @ark o o sh.qqn
David H. Arkoosh
Law Office of David Arkoosh
PO Box 2817
Boise, ID 83701
davi d (@arkoo shl aw. com
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road Madison, WI 53711
dbender@earthj ustice. ore
Briana Kober
Vote Solar
360 22nd Street., Suite 730
Oakland, CA946l2
[e-mail]
Snake River Alliance and Northwest Enerry
Coalition
John R. Hammond, Jr.
Fisher Pusch LLP
101 5. Capitol Blvd., Suite 701
P0 Box 1308
Boise, ID 83701
irh@)frshemusch.com
Electronic service only:
Snake River Alliance
wwil [e-mail]
NW Energy Coalition
[e-mail]
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
Kirton McConkie
50 East Ternple, Suite 400
P0 Box 45120
Salt Lake City, UT 841I I
r ti azi er (Qkrn c I aw. co m
[e-mail]
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
dous@imwindandsolar. com
dale@imwindandsolar. co
W\eNutw
Kelsey Jae Nunez, Attomey for Sierra Club
Idaho Sierra Club - First Production Request to Idaho Power Company - IPC-E-I7-13 - 9